AML - entry into force of the amendment on UBO / BR verification.

On 31.10.2021, the last provisions of the AML amendment of 30.03.2021 will come into force. Obligated institutions (including factoring companies), are required to update their internal AML procedure in terms of:

1. rules to note discrepancies between the data available in the CRBR and the findings on the person of the real beneficiary (BR / UBO), made in-house;
2. Rules for documenting impediments to verification of the BR's identity and actions taken in connection with the identification as a BR of an individual in a senior management position (this refers to such impediments that make it impossible or doubtful to determine the BR's person).

The above-mentioned amendment entails updating AML procedures and documentation.